1. Data Controller and contact details

The Data Controller is Kismet S.r.l., registered office at Via Roma 128, 18038 Sanremo (IM), Italy, VAT No. 00271330086 (“Kismet” or the “Controller”).

Privacy contacts: info@sanremojunior.it – sanremojunior@gef.it – telephone +39 0184 570300. Website: www.sanremojunior.it.

Internal contact for responding to data-subject requests: Ms Sonja Viveka Fager. This does not constitute the appointment of a Data Protection Officer (DPO), unless one is formally appointed.

2. Data subjects and sources of data

This notice concerns the minor participant and those holding parental responsibility or legal guardianship. Data are collected directly from the data subjects or from the person submitting the application. For international delegations, data may also be received from an authorised national licensee or selector, school, association, academy or accompanying person. Anyone providing another person’s data declares that they are authorised to do so and undertakes to provide that person with this notice.

3. Categories of personal data

• identity and contact data of the participant and parents/guardians, including date and place of birth, nationality/citizenship, tax identification number, address, contact details and signatures;
• documents and information needed to verify identity, age, citizenship and eligibility, including copies of identity documents where requested;
• entry and artistic information, curriculum vitae, school/organisation, contact details of the named teacher, song, composers, lyricists, publishers, language, duration, backing track, SIAE documentation, rehearsals, performance, scores, rankings, prizes and organisational communications;
• administrative, accounting, tax, banking and payment data, including the payer’s details;
• photographs, image, voice and audio/audiovisual recordings of the performance and related event activities;
• health, disability, allergy or accessibility/safety information, only when voluntarily supplied and strictly necessary.

Please do not send unnecessary data, particularly health information that is not essential.

4. Purposes and legal bases

5. Mandatory and optional information

Data marked as mandatory and the authorisation required to record and communicate the performance are necessary to take part in a public contest broadcast by live stream. If they are not provided, entry or participation cannot proceed. Consent to additional future promotional use is optional; refusing it does not affect the application, selection or participation.

6. Processing methods and security

Data are processed on paper and by electronic and online systems in accordance with lawfulness, fairness, transparency, data minimisation, accuracy and storage-limitation principles. Kismet adopts technical and organisational measures appropriate to the risk under Article 32 GDPR and authorises only personnel and collaborators who need the data for their duties. No system can guarantee absolute security, especially for content lawfully made public online.

7. Recipients and public dissemination

Where strictly necessary, data may be disclosed to:

• staff, collaborators, jury members, artistic management, orchestra, technicians, accreditation and security personnel;
• national licensees/selectors, the participant’s school or organisation and authorised organisational partners;
• theatres, broadcasters, audiovisual producers, SIAE or other rights-management organisations, accommodation providers, travel agents/tour operators, carriers, insurers and requested service providers;
• IT, hosting, cloud, email, entry-management, payment, audiovisual production, streaming, printing and social-media providers, acting as processors under Article 28 GDPR where they process data for Kismet;
• legal, tax and accounting advisers, banks, public authorities and supervisory bodies where required by law.

The participant’s name or stage name, represented country, image, voice, performance, results and awards may be made public through the channels described in this notice. Other personal data will not be publicly disseminated.

8. Transfers outside the EEA and worldwide availability

Live streaming and online publication make audiovisual content accessible worldwide. Some technology providers or platforms may also process data outside the European Economic Area. Where Kismet makes a transfer subject to Chapter V GDPR, it relies on a European Commission adequacy decision or appropriate safeguards, such as Standard Contractual Clauses, with supplementary measures where necessary. Platforms acting as independent controllers also apply their own privacy notices. Once lawfully published online, images and videos may be copied or reshared by third parties beyond Kismet’s control.

9. Retention periods

• unsuccessful applications: normally up to 12 months after the relevant edition, unless needed for legal claims;
• administrative, contractual, tax and accounting data: 10 years after the relationship ends, or for any different period required by law;
• complaints or disputes: for as long as needed to manage them and until applicable limitation periods expire;
• health/accessibility data: only for the period strictly necessary to manage the event, unless law or a dispute requires longer retention;
• rankings, hall of fame and audiovisual content having documentary, historical or archival value: potentially indefinitely, subject to proportionality and data minimisation;
• material processed on the basis of optional promotional consent: until consent is withdrawn, without affecting prior lawful use and subject to the technical time needed to remove it from channels controlled by Kismet.

10. Automated decision-making and artistic assessment

Kismet does not make decisions based solely on automated processing that produce legal or similarly significant effects within Article 22 GDPR. Admissions, scores and rankings result from human assessment under the Contest Regulations. Communicating outcomes and publishing results form part of participation.

11. Data-subject rights

Where Articles 15–22 GDPR apply, the data subject may request access, rectification, erasure, restriction, portability, or object to processing based on legitimate interests, and may withdraw consent at any time without affecting earlier lawful processing. Erasure and objection do not apply where processing must continue for legal obligations, legal claims or another overriding legal basis. Withdrawal cannot recall material already printed, broadcast, downloaded or reshared by third parties; however, Kismet will stop new uses based solely on consent and, where technically and legally possible, act on channels it controls.

Requests may be sent to info@sanremojunior.it or by post to Kismet S.r.l., Via Roma 128, 18038 Sanremo (IM), Italy. Kismet may request information needed to verify identity and authority. A complaint may also be lodged with the Italian Data Protection Authority (www.garanteprivacy.it) or the competent supervisory authority in the data subject’s EU Member State of residence or work.

12. Updates

This notice may be updated following legal, organisational or technological changes. Material changes will be communicated appropriately. Version: 1 September 2026.